20220511PAC to PIIC 1-24 - Redacted.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
May 11, 2022 Ronald L. Williams, ISB No. 3034 Jonathan D. Wheatley, ISB No. 11537 Hawley Troxell Ennis & Hawley LLP
877 West Main Street Boise ID, 83701 [e-mail] (C) [e-mail] (C)
RE: ID PAC-E-22-05 PIIC Set 1 (1-24) Please find enclosed Rocky Mountain Power’s Responses to PIIC 1st Set Data Requests 1-2, 7-14, 19, and 22. The remaining response will be provided separately. Also provided via e-mail
are the non-confidential Attachments. Confidential Attachments and the Confidential Response PIIC 8 are provided via BOX. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding. If you have any questions, please feel free to call me at [phone]. Sincerely,

____/s/____ J. Ted Weston Manager, Regulation Enclosures C.c.: Jan Noriyuki /IPUC [e-mail] (C) Joseph Terry/IPUC [e-mail] (C) Donn English/IPUC [e-mail]
Bradley Mullins/PIIC [e-mail] (C)
Val Steiner/Itafos Conda, LLC [e-mail] Kyle Williams/BYU Idaho [e-mail] Thomas J. Budge/Bayer [e-mail] (C) Brian C. Collins/Bayer [e-mail] (C) Greg Meyer/Bayer [e-mail] (C)

RECEIVED
2022 May 11, PM 4:51
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 1
PIIC Data Request 1 Please provide all questions and answers to all prior data requests between RMP and Commission Staff, and all other parties in this case, including questions and
answers that contain confidential information.
Response to PIIC Data Request 1
Please refer to Attachment PIIC 1-1 and Confidential Attachment PIIC 1-2.
Going forward, the Company will copy the PacifiCorp Idaho Industrial Customers (PIIC) on all outgoing responses and requests. The Company does not waive any objections raised in the data request responses
included in the attachments.
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject
to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding. Recordholder: Not applicable
Sponsor: Not applicable

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 2
PIIC Data Request 2 Please provide electronic versions of all exhibits and work papers, with all formulas and links intact, supporting Rocky Mountain Power’s filing in this case.
Response to PIIC Data Request 2 Please refer to Attachment PIIC 2-1 and Confidential Attachment PIIC 2-2.

Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Not applicable Sponsor: Not applicable

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 7
PIIC Data Request 7 Please provide detail of all pipeline charges and fees accrued in the 2021 deferral period, including detail of each contract, the counterparty, the tariff rates, the
capacity, and the cost.
Response to PIIC Data Request 7
Please refer to Confidential Attachment PIIC 7.
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: John Akiyama
Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 8
PIIC Data Request 8 Please explain and provide details as to whether PacifiCorp incurred any overrun or underrun entitlement charges on any pipeline in the 2021 deferral period?
Confidential Response to PIIC Data Request 8 Please refer to the Company’s response to IPUC Audit Data Request 15,
specifically Confidential Attachment IPUC Audit 15, file “2021
PipelineImbalanceCharges CONF” which provides pipeline imbalance charges during calendar year 2021. Yes, the Company incurred overrun and or underrun charges in 2021 for from
Questar Gas Company (QGC). The QGC tariff requires all transportation bypass
firm (TBF) to maintain a +/- 5 percent daily transportation imbalance. All daily imbalance exceeding the +/- 5 percent allowable imbalance, receives a daily transportation imbalance charge per dekatherm (Dth) as noted in the QGC tariff.

Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Stephen Fendrich / Amy Meyer / John Akiyama Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 9
PIIC Data Request 9 Please provide work papers supporting the calculation and allocation of fuel supplies costs to each of PacifiCorp’s natural gas power plants in the 2021
deferral period.
Response to PIIC Data Request 9
Allocations of fuel supply (natural gas) costs to each of PacifiCorp’s natural gas
power plants is an automated process, therefore, no work papers supporting the calculation/allocation of such costs exist. However, please refer to Confidential Attachment PIIC 9 which provides an explanation as to how natural gas allocation to power plants is done.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: John Akiyama Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 10
PIIC Data Request 10 Please provide the GAAP trial balance from the Bridger Coal Company for the 2021 deferral period.
Response to PIIC Data Request 10 Please refer to Confidential Attachment PIIC 10.

Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Dan Moody Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 11
PIIC Data Request 11 Please provide the GAAP financial statements, including a Balance Sheet, Income Statement and Statement of Cashflows, from the Bridger Coal Company for the
2021 deferral period.
Response to PIIC Data Request 11
Please refer to the Company’s response to PIIC Data Request 10.
Recordholder: Dan Moody Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 12
PIIC Data Request 12 Please provide the operating results from the Bridger Coal Company used to derive the cost of coal consumed at the Jim Bridger Power Plant in the 2021
deferral period.
Response to PIIC Data Request 12
Please refer to the Company’s response to PIIC Data Request 10.
Recordholder: Dan Moody Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 13
PIIC Data Request 13 Please provide transaction level accounting data for 2021 using a format identical to PacifiCorp’s response to Staff Data Request 57 in Docket UE 399 before the
Oregon Public Service Commission, including detail of the Idaho allocated
amounts. Please provide the transaction level accounting detail for FERC accounts 447, 456, 419, 557, 501, 503, 547, 555, 557, 565, 566. Note that while some of these are not NPC accounts, PIIC is reviewing them to evaluate whether
revenues and costs were appropriately attributed to NPC accounts.
Response to PIIC Data Request 13 PacifiCorp objects to this data request on the grounds that it is overly broad and burdensome not reasonably calculated to lead to the discovery of admissible
evidence in this Energy Cost Adjustment Mechanism (ECAM) proceeding.
Subject to and without waiving the foregoing objections, PacifiCorp responds as follows:
Please refer to Confidential Attachment PIIC 13.
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Craig Stelter
Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 14
PIIC Data Request 14 Please provide a copy of PacifiCorp’s FERC Form 1 for 2021, including all supporting schedules and workpapers.
Response to PIIC Data Request 14 The Company objects to this request, due to the voluminous amounts of data that
is predominately irrelevant to this proceeding. Please refer to Attachment PIIC 14
for a copy of PacifiCorp’s 2021 annual Federal Energy Regulatory Commission (FERC) Form No. 1. The Company requests that the PacifiCorp Idaho Industiral Customers (PIIC) to make specific sub-selections based on FERC page numbers.
Recordholder: Not applicable
Sponsor: Not applicable

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 19
PIIC Data Request 19 To the extent not already provided, please provide all of the minimum and additional filing requirements submitted in the Utah Energy Balancing Account
(EBA), UT PSC Docket No. 22-035-01 for the 2021 deferral period, except
those filing requirements specifically related to the calculation of the EBA. At a minimum, please provide the responses to EBA FR 1 (substituting Idaho for Utah), EBA FR 6, and AFRs 1 – 20 (i.e. all AFR responses).
Response to PIIC Data Request 19 PacifiCorp objects to this data request as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Utah’s filing requirements are specific to the Company’s Utah energy balancing account
(EBA), which is calculated differently than the Idaho energy cost adjustment
mechanism (ECAM). Most of the Utah EBA minimum filing requirements and additional filing requirements do not apply to the Idaho ECAM or would require the Company to conduct additional analysis that it has not performed.

Recordholder: Ted Weston Sponsor: To Be Determined

PAC-E-22-05 / Rocky Mountain Power May 11, 2022 PIIC Data Request 22
PIIC Data Request 22 Please provide PacifiCorp’s forecast MWh sales on a monthly basis by rate schedule over the period May 2022 through July 2023.
Response to PIIC Data Request 22 PacifiCorp objects to this data request as overly broad, unduly burdensome, and
not reasonably calculated to lead to the discovery of admissible evidence. The
Idaho Public Utilities Commission (IPUC) has historically relied on actual loads not forecasted loads as the basis of jurisdictional and class allocations. Rate design for the energy cost adjustment mechanism (ECAM) is based on the normalized historical megawatt-hours (MWh) sales from the most recent general rate case (GRC) as shown in Exhibit No. 2 to this Application and the work
papers supporting the direct testimony of Company witness, Robert M. Meredith.
Recordholder: Robert Meredith

Sponsor: Robert Meredith